Privacy Policy

This is a translation provided for convenience. In the event of any discrepancy, the Portuguese version prevails.

Wharbz Imóveis Ltda

Wharbz Imóveis Ltda, a private legal entity registered under CNPJ No. 45.941.497/0001-80 (Brazilian corporate taxpayer number), headquartered at Rua Embuaçu, No. 16, Vila Mariana, São Paulo/SP, Brazil, hereinafter referred to as "Wharbz", respects the privacy and protection of the personal data of its clients, partners, suppliers and users, and undertakes to process such data in compliance with Brazil's General Data Protection Law, LGPD (Law No. 13,709/2018).

The purpose of this Policy is to explain how personal data is collected, used, stored, shared and protected.

1. Personal data collected

Depending on the legal relationship established, Wharbz may collect the following data:

• Identification data: name, CPF (Brazilian individual taxpayer number), RG (Brazilian identity card), CNPJ, marital status;
• Contact data: address, email, telephone;
• Property and asset data: property information, property registration records, contracts, certificates;
• Data required to formalize purchase and sale, lease, brokerage and real estate regularization agreements;
• Data provided voluntarily through forms, email, WhatsApp, telephone or in-person service.

On the wharbz.com website, we collect the data provided in the contact form: name, telephone or WhatsApp number, and email. This website may also use analytics and marketing cookies, always subject to your prior consent, requested through the cookie banner displayed on your first visit. You may accept or reject non-essential cookies at any time, and your choice can later be changed through your browser settings. Along with your message, we record the page of the website from which the contact was sent, so we understand the subject of your request. Only if you accept cookies do we also record how you arrived at the website (the first page visited, the referring website and the link's campaign, such as utm_source), so we understand which channels work best. You can review your cookie choice at any time through the “Cookie preferences” link in the footer.

2. Purpose of data processing

Personal data is processed for legitimate, specific and necessary purposes, such as:

• Provision of real estate services and related legal services;
• Drafting, reviewing and performing contracts;
• Compliance with legal, regulatory and tax obligations;
• Communication with clients and partners;
• Fraud prevention and ensuring the legal certainty of transactions;
• Regular exercise of rights in administrative or judicial proceedings.

3. Legal basis for processing

The processing of personal data follows the legal bases set out in Articles 7 and 11 of the LGPD, in particular:

• Performance of a contract or of preliminary procedures;
• Compliance with a legal or regulatory obligation;
• Regular exercise of rights;
• Consent of the data subject, where applicable;
• Legitimate interest, respecting the fundamental rights and freedoms of the data subject.

4. Confidentiality and electronic communications

Communications sent by Wharbz, including by email, are intended exclusively for the indicated recipient(s) and may contain confidential information protected by professional secrecy.

If a message is received in error, the recipient must delete it immediately and notify the sender; any form of disclosure, reproduction or misuse is prohibited.

As an information security measure, Wharbz does not request passwords, access codes or sensitive data by email.

5. Data sharing

Personal data may be shared only when necessary, with:

• Notary offices and real estate registry offices;
• Financial institutions;
• Lawyers, accountants and service providers essential to the transaction;
• Public authorities, pursuant to a legal obligation or court order.

Whenever possible, sharing will be limited to the minimum necessary, preserving confidentiality and security.

6. Data storage and security

Wharbz adopts appropriate technical, administrative and organizational measures to protect personal data against unauthorized access, loss, alteration, destruction or improper disclosure.

Data is stored for the period necessary to fulfill the stated purposes or as required by law. Contacts sent through the website form are also kept in a protected backup copy, with no internet access, which is automatically deleted after 90 days, so that no request is lost.

To operate the website and email communications, Wharbz uses technology providers, such as email and hosting services, which may store or process personal data on servers located outside Brazil.

7. Data subject rights

Under the LGPD, the data subject may request at any time:

• Confirmation that processing takes place;
• Access to the data;
• Correction of incomplete, inaccurate or outdated data;
• Anonymization, blocking or deletion, where applicable;
• Portability of the data to another service provider;
• Information about any sharing carried out;
• Withdrawal of consent, where this is the applicable legal basis.

To exercise any of these rights, write to ethics@wharbz.com, Wharbz's channel for privacy and personal data protection matters.

8. Whistleblowing and Ombudsman Channel

Wharbz maintains a Whistleblowing and Ombudsman Channel for reporting irregularities, privacy violations, misuse of data, unethical conduct or breaches of this Policy.

Ombudsman email: ethics@wharbz.com

Reports will be handled with confidentiality, good faith and responsibility; any form of retaliation is prohibited.

9. Links to third-party websites

This website contains links to third-party websites, such as the official directories of the certification bodies mentioned in our content, WhatsApp and the social networks on which Wharbz maintains profiles. These websites are operated by third parties, with their own privacy policies and terms of use.

Wharbz does not control and is not responsible for the content, availability, accuracy of information or privacy practices of these websites, which may change without notice. A reference to a third-party website does not imply endorsement, partnership or affiliation with its operator. We recommend consulting each website's privacy policy when accessing it.

10. Updates to this Policy

This Privacy Policy may be updated at any time to reflect legal or operational changes; periodic review is recommended.

This Policy is governed by Brazilian law.

11. Contact